Automated payments and Federal Reserve account access

Federal Reserve · Policy submission ·

Examines automated payment activity under the proposed Payment Account framework. Recommends wording that preserves case-by-case review, including scrutiny of automation and illicit-finance risk, without creating a separate category of payment activity.

Read the comment on federalreserve.gov (PDF, 6 pages)

The document

Title
Comment on the proposed revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests
Docket
OP-1878
Comment ID
FR-2026-0013-01-C86
Questions answered
Question 1 only
Capacity
Personal capacity
Submitted
Length
6 pages

The assessment it gives

The design would support the payment activity of legally eligible institutions whose activity settles over the services the proposal would permit, is fully prefunded, and leaves closing balances within a Closing Balance Limit calibrated to expected payment flows.

The comment is explicit that this is an assessment of design fit. Whether institutions would in fact choose the account depends on pricing and correspondent economics, which it does not address.

The one recommendation

In the final discussion of how the Account Access Guidelines would apply to Payment Account requests, the Board should state expressly, as discussion text rather than an account term:

“Automated initiation neither creates a separate category of payment activity under the Payment Account terms nor narrows the case-by-case review the Account Access Guidelines call for. The nature and extent of an institution’s automation remain relevant to that review, including to a Reserve Bank’s assessment of illicit finance risk under Principle 5.”

Where automation is material to an applicant’s model, heavier evidentiary expectations are a legitimate outcome of that review, and the proposed Part IV illicit-finance mitigants would remain available in full.

What it does not ask for

The recommendation requires no change to proposed Part IV of the Federal Reserve Policy on Payment System Risk. It adds no new account term and no new application requirement.

The comment takes no position on statutory eligibility, and none on Questions 2 through 7.

Sources